When 527 CMR 33 came into effect back in 2012, all facilities utilizing hazardous materials were required to thoroughly evaluate their processes using hazardous materials. There was a phased-in implementation of the regulation based on the category of processes taking place, and many facilities dedicated a lot of time to conducting this evaluation. This Hazardous Material Process or Processing regulation has since been superceded by 527 CMR 1.00, but the requirements stipulated in 527 CMR 1.60.8 remain the same.
527 CMR 1.60.8 applies to new and existing facilities that process hazardous materials. There are numerous exemptions to the processes covered by this regulation, but facilities are required to evaluate all of the processes that involve or produce a hazardous material that occur in a vessel. It is important to keep this hazardous material processing regulation in mind as the processes and procedures taking place at your facility change. If you conducted an evaluation several years ago when the initial regulation came into effect and have not considered it again since then, take the time to document a current evaluation of applicability to the processes currently taking place.
During lab safety training refreshers, remind everyone about this regulation and ask them to keep you informed about changes to their processes. Scale up of processes and new processes need to be evaluated for safety and applicability of permitting needs.